Implementation of a Commuter Wharf Access
Permit for Sydney Harbour
CONSULTATION DRAFT
February 2015
Maritime Management Centre
Version Number: 07
Page 1 of 8
1
Introduction ......................................................................................................................................................... 3
2
Scope.................................................................................................................................................................... 3
3
Nature of permit .................................................................................................................................................. 3
4
Compliance........................................................................................................................................................... 4
5
Options for monitoring wharf usage ..................................................................................................................... 4
5.1
Automatic Information Service (AIS) ....................................................................................................................... 4
5.2
RFID ......................................................................................................................................................................... 5
5.3
Remote Cameras / Existing Wharf Cameras ........................................................................................................... 6
5.4
Periodic Survey ........................................................................................................................................................ 6
5.5
Strengths and Weaknesses ...................................................................................................................................... 6
5.6
Conclusion ............................................................................................................................................................... 7
6
Regulatory framework.......................................................................................................................................... 7
7
Permit Conditions ................................................................................................................................................. 7
8
Implementation ................................................................................................................................................... 8
Attachment A - TfNSW Wharf Access Policy
Attachment B - Draft Ports and Maritime Administration Amendment (Wharf Access) Regulation 2015
Maritime Management Centre
Version Number: 07
Page 2 of 8
1 Introduction
On 24 April 2014 Transport for NSW (TfNSW) announced a new Wharf Access Policy for
Roads and Maritime (RMS) owned wharves on Sydney Harbour (Attachment A). A key
element of this policy is the introduction of a Commuter Wharf Permit System that allows
commercial passenger vessels to obtain a permit allowing them to access certain wharves
on the harbour.
The permit scheme will operate independently and separately to the existing RMS Charter
Wharf Booking System which applies to wharves identified as Charter Wharves. A list of
the Charter Wharves and Commuter Wharves is provided in the Wharf Access Policy.
The permit scheme will allow permit holders to use the Commuter Wharves in order to
pickup and set down passengers, with vessels occupying the wharf for less than 5 minutes.
Permit holders will need to ensure that priority access is maintained for Sydney Ferries
services.
2 Scope
The number of Commercial Passenger vessels operating on Sydney Harbour varies due to
seasonal and economic influences. RMS has advised that there are approximately 400
vessels that have their home port listed as Port Jackson that conduct commercial
passenger operations. This includes vessels engaged in charter or water-taxi operations.
In addition to this, there are a number of domestic commercial vessels that come with a
National certificate or survey and operation from another state or territory who may benefit
from utilising the permit scheme and are operating within Port Jackson.
Under the scheme any commercial vessel seeking to pick up or drop off passengers at a
Commuter Wharf will be required to obtain a permit1.
3 Nature of permit
A Commuter Wharf Permit is issued for a period of 12 months and may cover one or more
commercial vessels owned by a commercial vessel operator.
Conditions may be applied to a Commuter Wharf Permit, for example, access to a particular
wharf may be restricted to particular times of day to ensure priority access is maintained for
Sydney Ferries services.
A Permit does not provide a booking to use a wharf at a particular time and date, rather it
allows a vessel to pick up and drop off passengers on a “touch and go” basis with berthing
times limited to five minutes.
1
Services operating under a service contract to Transport for NSW under the Passenger Transport Act are exempt from
the requirement to obtain a permit, where the service contract authorises use of a commuter wharf through other
means.
Maritime Management Centre
Version Number: 07
Page 3 of 8
Permit holders providing services in accordance with a regular timetable will be given
priority over other wharf users, except Sydney Ferries services which have priority over the
services of all permit holders.
Fees for a Commuter Wharf Permit are based on usage and are set out in the TfNSW
Wharf Access Policy (Attachment A).
Initial feedback from industry has suggested the need for a threshold of wharf usage, below
which operators are not required to hold a permit. It has been suggested that there are
some operators who generally operate outside of Sydney Harbour but may come into the
harbour occasionally to operate charter services during major events. Further comment is
sought to help determine an appropriate threshold that ensures very occasional wharf users
are not unnecessarily impacted by the Permit Scheme.
4 Compliance
There are two elements to ensuring compliance with the Commuter Wharf Permit scheme:
a) Being able to identify when a commercial vessel is using a Commuter Wharf without
the operator holding a permit.
b) Being able to monitor how many times a permit holder berths at a Commuter Wharf
over twelve month period.
RMS’ Authorised Officers will undertake compliance activities to check whether an operator
of a commercial vessel using a Commuter Wharf has a valid permit. This may include ‘spot
checks’ or more targeted compliance campaigns including acting in response to reports and
intelligence received from other operators.
As it is neither practical nor cost effective to utilise a person with the sole responsibility of
visually monitoring how often an operator berths at a Commuter Wharf, a technology based
solution is required.
5 Options for monitoring wharf usage
5.1
Automatic Information Service (AIS)
AIS was developed primarily to allow ships to view marine traffic in their area and to be
seen by that traffic. The system uses a dedicated VHF AIS transponder that regularly
transmits a package of information including vessel identification, location, orientation and
speed. Port authorities or other shore-based facilities use AIS, so that they can view the
local traffic without the need to transmit their own location.
All AIS transponders are limited by VHF radio range, but numerous receivers can be utilised
to improve reliability of reception. The information transmitted by vessels would be filtered
by computer to identify when a vessel has used a wharf.
Maritime Management Centre
Version Number: 07
Page 4 of 8
The technology is already utilised by some of the larger / faster vessels that currently
operate on Sydney Harbour. The Port Authority of NSW utilises AIS and manages base
station receivers in AMP Tower and at La Perouse to assist with the monitoring of vessels in
the Sydney region.
Key points relating to the use of AIS for the Commuter Wharf Access scheme are listed
below.
 The operation of a commuter wharf permit scheme that is capable of recording wharf
use by compliant vessel operators with reasonable accuracy should be achievable
through the use of AIS.
 A number of commercial passenger vessels on Sydney Harbour already have AIS
installed and use it to supplement their navigational instrumentation on board the
vessel.
 Operators would be required to be responsible for the purchase, install and operation
of an appropriate transceiver for each vessel.
 AIS can be used by vessel masters as a supplementary navigational aid.
 Aside from the proposed requirement to operate AIS as part of the Permit scheme,
and separate to any other legislative requirements, the installation of AIS on
commercial passenger vessels inside port Jackson is supported by Port Authority of
NSW, Roads and Maritime Services and the Office of Transport Safety
Investigations.
RFID
5.2
Radio Frequency Identification (RFID) is a technology that is in common use in numerous
areas of society. Notably, RMS and other road managers use RFID technology to monitor
road use on tollways and bill users accordingly.
The standard hardware available for RFID systems can detect “tags” out to a range of 10
meters. A “base” reader would be required to be set up on each wharf. When a tag comes
within range the reader would record the event and send the information by remote 3G
telecommunications network to a central location where usage from all wharves would be
recorded.
Some larger vessels may require more than one tag to ensure the wharf use is correctly
captured. Additionally, for this technology to be used effectively it must be paired with some
form of optical recognition system. RMS use numberplate recognition software and road
sensors to automatically photograph a vehicle passing an isolated point in the road.
RFID would not be able to confirm unauthorised use without significant investment in
cameras and incurring the ongoing cost of manual review. Noting the number of vessels
that may be subject to the permit scheme, the level of compliance required to utilise RFID
and the use of an operator to manually scan and check images captured may negate the
benefits of RFID technology.




RFID hardware would cost approximately $10,000 per wharf.
Vessel tags cost approximately $5-$10 per unit for each vessel.
Does not capture unauthorised use.
Requires significant ongoing use of remote area cameras to determine unauthorised
access.
Maritime Management Centre
Version Number: 07
Page 5 of 8

5.3
Provides minimal to no supplementary benefit to anyone when used with remote
cameras.
Remote Cameras / Existing Wharf Cameras
Camera purchase and installation costs range from $3,000 to $5,000 per camera unit with
ongoing 3G network fees of approximately $30 per unit / month applicable for data transfer
to a central location.
The use of remote cameras as a single means to record wharf use requires significant
manual intensive work to record berthing – both legal and illegal.
The use of current camera installations maintained by Sydney Ferries and supplementation
of cameras where required on Commuter Wharves could be undertaken with supplementary
benefit provided to a range of other stakeholders including HCF, Transport Management
Centre, Maritime NSW and NSW Police.
Roads and Maritime currently operate cameras that provide images of various areas within
Sydney Harbour. The images that these cameras capture are not suitable for the purposes
of providing satisfactory vessel identification for the Wharf Access Permit Scheme.
5.4
Periodic Survey
Periodic Survey is defined as the use of manual labour placed on site to record the usage of
wharves by various vessels and monitoring their compliance with the Wharf Access
Scheme.
Even if used at various times of the year to obtain a statistically relevant sample, the
number of wharves that would need to be monitored and the hours of monitoring required
would make this an unsatisfactory method of primary scheme management.
However, the use of periodic survey while inherently inefficient and costly may have limited
application where a problem area / wharf has been specifically identified and needs to be
reviewed.
5.5
AIS
RFID
Strengths and Weaknesses
Strengths
Weakness
Effectiveness
Data rich. Reports wharf
usage, dwell time,
failure to provide access
to Sydney Ferries.
Improvements to marine
safety.
Introduction supported
by NSW Ports & RMS.
Provides vessels with an
additional navigational
aid if not already fitted.
Established technology
with existing examples
of use available.
Untested adaptive use
of technology.
Requires trial period to
test operation.
Should provide an
automated report of
wharf usage that
can be displayed by
scheme
administrator. Also
allows vessels to
“see each other”
and take action to
minimise
congestion.
Limited. Does not
show complete
wharf use picture.
Maritime Management Centre
Does not capture use
by vessels who do not
have AIS.
Limited information
capture.
Does not capture
Version Number: 07
System Costs
Capital /
Recurrent
Upwards
$2k AIS /
of $600
GIS
per
software
vessel.
and data
Admin
hosting.
Software
purchase
up to $3k.
$205k
System +
$8 per
$7k $24k per
month
Page 6 of 8
Remote
Camera
Could assist TfNSW /
Sydney Ferries with
demand management
and provide improved
wharf security. Images
can be retrieved for use
at a later date as
required for evidence.
Periodic
Survey
Confirms wharf use.
Proven low technology
solution.

vessels that do not
have RFID tag.
Labour / cost
intensive. Motion
sensing cameras still
require review and
manual administration.
Reflections on water
plus pedestrians can
trigger camera even
with advanced
“sectorisation” of
motion sensing
camera field.
Not covert and may
not be seen as a
deterrent unless
utilised extensively.
tag.
May be useful at
targeted
problematic
wharves.
$3k-$5k
per
camera
May be useful at
targeted
problematic
wharves.
Nil
reporting
package.
$30 per
mth per
camera.
Requires
labour
intensive
image
review.
$25 per
hour, per
wharf.
Costs do not include TfNSW general administration costs
5.6 Conclusion
Based on the above analysis the use of AIS technology would appear to primarily provide
the most effective and efficient means for monitoring wharf usage. Industry feedback is
sought to help confirm this conclusion and identify any implementation or operational
issues.
6 Regulatory framework
It is proposed that introduction of the Permit Scheme will be supported by an amendment to
the Ports and Maritime Administration Regulation 2012. A draft version of the regulation is
provided at Attachment B for comment.
7 Permit Conditions
The proposed regulation provides for the inclusion of conditions to a Commuter Wharf
Permit, with possible penalties to apply if a permit holder does not comply with the
conditions. It is proposed that the conditions will generally relate to the following issues:
 Requirement to pay the wharf access fee associated with the relevant wharf usage
category.
 Requirement for vessels to have AIS operational with the correct vessel details
transmitting when operating inside Sydney Harbour.
 Wharves may be closed or access restricted for operational reasons (eg
maintenance) or if usage of the wharf by permit holders impacts on the priority
access afforded to Sydney Ferries.
 Arrangements for suspending or cancelling a permit in the event of breach of a
condition.
Maritime Management Centre
Version Number: 07
Page 7 of 8


Arrangements for permit renewal, noting that it is intended renewal will simply be a
matter of paying the relevant fee for the next period.
Refund arrangements should an operator seek to cancel a permit.
8 Implementation
It is proposed to commence the Permit Scheme on 1 July 2015, with operators able to
obtain a permit from May 2015. An initial amnesty period is being considered to assist
operators with the transition to the new system, including an initial free access period where
operators can obtain a permit without having to pay the relevant fee. Industry comment is
sought on measures which may assist with implementation.
Maritime Management Centre
Version Number: 07
Page 8 of 8